Privacy Policy

Japan Excellent Asset Management Co., Ltd. (“JEAM”) recognizes the protection and appropriate management of personal information as one of its key social responsibilities and is committed to doing so based on the following privacy policy, which governs the handling of personal information possessed by JEAM.

With regard to individual numbers and specific personal information (each as defined in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures, or Act No. 27 of 2013), JEAM shall separately formulate a basic specific personal information policy and comply with it.

Fundamental Policy

JEAM strives to implement appropriate handling and sound, rigorous control and management of personal information while complying with the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as the Personal Information Protection Act), other related laws and regulations, and internal regulations.
Moreover, JEAM continuously reviews its privacy policy in order to meet its legal requirements and further improve its protection of personal information.

Handling Personal Information

1. Acquiring and Using Personal Information

JEAM shall acquire personal information in an appropriate and legal manner within the scope required by its business (JEAM shall not acquire personal information requiring special care, as defined in the Personal Information Protection Act, without the prior consent of the relevant individual, unless otherwise stipulated by the applicable laws and regulations).
Moreover, it shall disclose or provide notification of the usage purpose of personal information, and unless otherwise stipulated by the applicable laws and regulations, handling of personal information shall not exceed the scope required to achieve the intended usage purpose without the consent of the relevant individual.

2. Usage Purpose of Personal Information

JEAM shall use personal information for the following purposes in order to conduct asset management and related operations entrusted by Japan Excellent, Inc. (“JEI”) in connection with JEI’s asset management business and related operations in an appropriate manner.
JEAM shall not use personal information in ways that foster illegal or improper conduct or that are liable to induce such conduct.

  1. a. To support holders of securities issued by JEI (“unitholders, etc.”) exercising their rights and JEI in fulfilling its obligations, as well as to implement other measures to strengthen the relationship between JEI and unitholders, etc.
  2. b. To prepare and submit various reports and other documents about JEI based on the Act on Investment Trusts and Investment Corporations (Act No. 198 of 1951; hereinafter referred to as the Investment Trusts Act) and other related laws and regulations, and stock exchange rules
  3. c. To manage unitholder information, such as creating data about JEI’s unitholders, etc.
  4. d. To support JEI borrowing funds, issue investment corporation bonds, and issue additional investment units
  5. e. To respond to inquiries regarding securities issued by JEI
  6. f. To conduct various business activities such as research, analysis, collection of materials, reviews, conclusion of contracts, and performance of contractual rights and obligations for the acquisition, operation, management, and disposal of assets under management of JEI
  7. g. To execute other business operations of JEAM or JEI in an appropriate, smooth manner
  8. h. To disclose or provide personal information to third parties within the scope required to achieve the usage purposes described in items a. to g. above

3. Provision of Personal Information to Third Parties

JEAM shall not provide personal information to third parties without obtaining the prior consent of the relevant individual, except in the following cases.

  1. a. When required by laws and regulations
  2. b. When it is necessary to protect human life, body, or property and obtaining the consent of the relevant individual is difficult
  3. c. When it is particularly necessary to improve public health or promote the sound upbringing of children and obtaining the consent of the relevant individual is difficult
  4. d. When it is necessary to cooperate with national or local governmental organizations or parties commissioned by them in order to carry out clerical work stipulated by laws or regulations and obtaining the consent of the relevant individual could hinder the carrying out of said clerical work
  5. e. When provision is permitted by the Personal Information Protection Act for other reasons

4. Safe Management Measures of Personal Data

  1. a. JEAM shall manage personal data of customers (referring to personal information which JEAM has acquired or is attempting to acquire and including those scheduled to be handled as personal data. The same applies in a. and b. below) appropriately and carefully and implement necessary and appropriate safe management measures to prevent unauthorized access, loss, falsification, leaks, etc. involving personal data (hereinafter referred to as “leaks, etc.”).
  2. b. In the event that leaks, etc. of personal data occur, JEAM shall implement countermeasures to minimize the damage and take corrective actions to prevent recurrence.
  3. c. In the event of a leak, loss, or damage of personal data, or in any other situation related to the security of personal data that represents a significant risk of harming the rights and interests of an individual occurs, as stipulated in the Ordinance for Enforcement of the Act on the Protection of Personal Information (Rules of the Personal Information Protection Commission no. 3 of 2016; hereinafter referred to as the “Ordinance for Enforcement”), (except in cases where JEAM has been entrusted by another business operator handling personal information with all or part of the handling of the personal data in question, and JEAM has notified the business operator handling personal information of the occurrence of the situation pursuant to the Enforcement Rules), JEAM will notify the relevant individual that the incident has occurred, as stipulated in the Ordinance for Enforcement. However, this shall not apply if it is difficult to notify the relevant individual and the necessary alternative measures are taken to protect the relevant individual’s rights and interests.

5. Outsourcing the Handling of Personal Information

In conjunction with the outsourcing of personal information handling, either in whole or in part, within the scope required to achieve its usage purposes, JEAM may provide customers’ personal information to another party.
In such a case, JEAM shall select a party that implements thorough measures to protect personal information and perform necessary and appropriate supervision of the outsourcee.

6. Consultation Services for Inquiries about Personal Information, Etc.

JEAM shall respond as promptly and sincerely as possible to complaints, inquiries, etc. concerning personal information.
Requests to disclose (including disclosure of records provided to third parties; the same applies hereinafter) or revise customers’ personal information possessed by JEAM, suspend its use, or stop providing it to third parties and questions or complaints submitted regarding the handling of personal information (safe management measures, etc.) based on the Personal Information Protection Act shall be handled by the following consultation services.

  1. a. Contact Information for Inquiries, Etc.
    [Information on point of contact for Japan Excellent Asset Management Co., Ltd.]
    Business Planning Dept. Phone: +81-3-5412-7911 (representative)
    (excluding Saturdays, Sundays, national holidays, and year-end and New Year’ holidays)
  2. b. Procedure for Requesting Disclosure of Personal Information
    In cases of a request to disclose, revise, or suspend use of personal information or stop providing it to third parties based on the Personal Information Protection Act, the procedures designated by the consultation services specified in item a. above will be followed.
    For details, please contact the consultation services indicated above.

7. Name of Authorized Personal Information Protection Organization and Contact Information for Complaint Resolution

JEAM is a member of the following authorized personal information protection organization authorized by the Financial Services Agency.
The authorized personal information protection organization accepts complaints and consultation requests regarding the handling of personal information of its members. Investor Consultation Office, Investment Management Association of Japan
Phone: +81-3-6821-8756

8. Modification of the Privacy Policy

JEAM may revise the privacy policy for the purpose of protecting customers’ personal information or to comply with changes in the laws, regulations, or standards. Please check the date of the latest update.

(Latest update: April 1, 2026)